You may already have made your mind up as to what you wish to do about stopping this scheme but please bear in mind when making your comments that we are somewhat in a dilemma for we cannot undo the approval that the original application was granted in 2014. If the present application is turned down then everything reverts to the original application with its increased area and depth of material to be dumped. Or we have the alternative with this latest application for an increase in the daily maximum number of lorry movements to 30, but combined with a decrease in the required amount of landfill material down from 100,000 tonnes to 72,000 tonnes, it should all result in the work being finished in less time than the original five years providing that enough material is locally available.

Whether you support or object to the changes we at least have the chance of restating our objections to either of the schemes. The real battle will begin when the developer applies for an Environment Agency license to carryout the work. As it is inevitable that it will come to this, informing ourselves and commenting on the present application will be good training for the real battle.

You may wish to see what this forum had to say on the original application by going to 'Harcombe Valley Peace Again Threatened' under this same Planning section. Sorry but the Rhodehillgardens website no longer exists so ignore the links._________________It's later than you think

For three years since planning permission was granted to turn the peaceful Harcombe Valley into an industrial wasteland, if only for five years!, the people of the Harcombe Valley have been living with the expectation of their peace being shattered at anytime by the sound of bulldozers stripping bare the top soil of the driving range of the Lyme Regis Golf Club to be followed by lorries disgorging thousand of tons of 'inert' waste, which would then be worked to depths of over 2.5 metres by bulldozers trundling up and down the hillside. But it didn't happen and perhaps we became complacent

The only thing stopping the commencement of the work was the nonexistence of a permit from the Environment Agency. An application was made for a Waste Recovery Plan later in 2014 but it was refused by the EA. The developer never submitted another plan perhaps because he knew that the EA would not grant one for the landfill operation as approved by Dorset County Council.

During the last three years, as you will know, all has not exactly been peace and quiet in Harcombe Valley. For a number of landfill operations have been proceeding on land adjacent to the driving range. These operations were under Waste Exemption agreements with the EA. These are small landfill operations not requiring an environmental permit.

I believe that during the last year the EA called a halt to some of these Waste Exemption activities. This is probably why we are now seeing an application to push on with the driving range landfill albeit with some of the conditions changed from the original application. You will have to decide for yourselves if there maybe a link between these halted Waste Exemption operations and the resurrection of the driving range landfill.

The main changes in the present application are that the maximum depth and the area covered by the added material will be reduced. This alone should mean that the work should be completed, with the same number of lorry movements per day, in less than the five years originally stated. All the same one of the proposed condition changes is that lorry movements should be increased to 30 per day. With all these changes why can't the developer guarantee that the project will be completed proportionally sooner than the still stated maximum of five years?

What are these changes to the original planning permission?
A list of these changes are given in the document:
Schedule 1 to Planning Permission Variation Application - April 2017.PDF

Condition No.2 Notification of Commencement.
This condition deals with the changes from dividing the area of the driving range into three rather than six cells. One cell will be worked at a time. Therefore a third of the proposed area will be worked as against a sixth of the slightly larger area of the original application. In fact 3.28 acres instead of the original 2.25 acres will be worked at any one time.

No.4 Development in Accordance with Approved Plans
Deals with changes in the profiles of the driving range.

No.12 Limitation on Type of Waste Brought onto Site
In this 'brick rubble and concrete rubble' has been changed to
'aggregates including mixtures of inert wastes of pre-crushed concrete, bricks, tiles and ceramics'. It remains to be seen how and where this concrete, bricks, tiles and ceramics will be processed off site.
We are also told that an Environmental Permit SR 2015 No.39 will be applied for. We now see why the total amount of waste to be used on the site has been reduced to 72,000 tonnes or 48,000m3 from 100,000 tonnes or 67,000 m3. Because this permit is only available for operations with a maximum volume of 60,000m3.

No.17 Maximum Importation of Material
This is increased from 10,000 tonnes, to 30,000 tonnes in any one calendar year. Elsewhere it is stated that Hansford deals in about 10,000 tonnes of waste per year. Where will the rest come from and will it, in line with No.12 above, be precrushed?

No.25 Limit on Access to Site
Changed from 20 loaded vehicles, to 30 loaded vehicles per day.

Plenty there that you can get your teeth into. Other points worth considering are:

Proximity of Dwellings to the Site
In the Planning Statement at 2.9 we are given the closest residential properties in all directions of the compass ranging between 350 and 450 metres from the closest boundary of the site. In 6.4.4 we are told what the noise levels will be at the nearest properties. In 6.4.5 we are told that noise and vibration levels should be acceptable 200 metres away at the Golf Club House. How reassuring. Then at 6.4.8 it is not considered that dust will a nuisance to nearby residential properties.

The date of the Planning Statement is April 2017. At this time 15 Starter home were being built already complete with roofs just 150 metres from the site. If such glaring objects so close to the site can be overlooked you must wonder what else has been overlooked intentionally or otherwise. The planning application must be rejected on this oversight alone.

It cannot be acceptable with hard working families living just 150 metres from the site that operations will start as early as 07:00 and go on until 19:00

Length of Operation
The stated decrease in the area and height of the landfill will result in only 72,000 tonnes of material being needed. Add to this the increase in the number of lorry movements the question springs to mind as to why is it still necessary for the operation to take up to five years. I suggest that the reason for the overall reduction is solely to enable the operator to apply for the Environmental Permit SR 2015 No.39 as stated in the Planning Permission Variation. This permit requires that the total amount of landfill must be under 60,000m3. The original planning permission's volume of material was 67,000m3 (100,000 tonnes) the new amount would be 48,000m3 (72,000 tonnes). Now we can see the probable reason that a permit was not obtained from the EA. If this change of conditions goes ahead and a permit it obtained then who will control the amount of material used in order to keep it under 72,000 tonnes? I no longer wonder why the operation will still take five years.

Pre-Crushing of Materials
The Planning Statement at 6.2.3 calls for all brick and concrete rubble to be reduced in size before being brought to site. This is open to interpretation. A demolished brick wall has already been reduced in size. The maximum acceptable size of material must be given. This condition also assumes that the person supplying the material has the facilities for the crushing of these materials. Hansford Construction may very well have this equipment but it is extremely unlikely that a small builder would.

Conclusion
I was originally minded that I would not object to these changed conditions on the understanding that with planning permission already granted for the original application it was a no brainer that a reduction in the amount of waste, area and height of the landfill (a misnomer if ever there was – this is not landfill in the normal sense of the word) would be an improvement. I am now of the opinion that the Environment Agency will not issue a permit for the original plan. This is why Hansford Construction are submitting the application to change these conditions.

I am now of the opinion that the original application as approved by the Dorset County Council has little chance of obtaining the necessary EA permit. Therefore I will help try to stop these changes in conditions taking place by objecting to the application. Hope that you can do likewise.